This chapter describes the early stages of developing a theory of learning, which offers an alternative perspective to those currently underpinning teaching and learning. It is not specific to higher education; indeed, it has been developed mainly from work at school level. However, the ideas are sufficiently general to apply to teaching and learning at university level, and there are already some examples of research in universities based on the theory. As it is still being developed, the status of 'theory' has yet to be attained: what is offered is better thought of as a 'framework', a way of thinking about learning within educational contexts. Its importance lies in directing the teacher's attention to the specific object of learning the actual content of what the student is expected to learn. The theory also suggests in general terms what is needed to make learning possible, and so is a pedagogical theory which has generally been referred to as variation theory, for reasons which will become clear.